From 11 September 2026, manufacturers of products with digital elements sold in the EU must report actively exploited vulnerabilities and severe security incidents to ENISA reporting platform (SRP) and their national CSIRT under Article 14 of the Cyber Resilience Act (Regulation (EU) 2024/2847). The CRA vulnerability reporting cascade runs on three deadlines: a 24-hour early warning, a 72-hour follow-up notification, and a final report within 14 days for vulnerabilities or one month for incidents.
CRA vulnerability reporting obligation applies to products already on the market, not only new ones, and it takes effect fifteen months before the rest of the CRA. Below is the exact sequence to follow when a reportable event happens, and what to have ready before it does.
What Triggers a CRA Reporting Obligation
Article 14 has two separate triggers. Ordinary bugs, patches, and routine vulnerability disclosures are not in scope. Only these two events start the CRA vulnerability reporting clock:
| Trigger | Definition | Reporting timeline |
|---|---|---|
| Actively exploited vulnerability | Reliable evidence that a malicious actor has exploited a vulnerability in your product in a live system, not a theoretical or lab-demonstrated flaw | 24-hour early warning, 72-hour notification, 14-day final report |
| Severe incident | An event that has an actual adverse impact on the security of the product with digital elements | 24-hour early warning, 72-hour notification, one-month final report |
If neither event has occurred, no Article 14 action is required. The CRA vulnerability reporting obligation is event-triggered, not a standing compliance programme you build in advance.
How to File a CRA Vulnerability Report
Total time to file: 12 hours
Step 1: Confirm the vulnerability trigger before the clock starts
Establish that you have reliable evidence of active exploitation, or a confirmed adverse security impact, not a suspicion or an unconfirmed report. The 24-hour CRA vulnerability reporting clock starts from the moment your organisation becomes aware, so this determination needs an owner and a decision point, not an open-ended internal debate. Document the time and basis of the determination itself — this timestamp is what a regulator checks first if your 24-hour report arrives late.
Step 2: File the 24-hour early warning on ENISA Single Reporting Platform (SRP)
Submit an early warning through the ENISA Single Reporting Platform (SRP). This first submission is deliberately thin: identify the product, state that a vulnerability is being actively exploited or that a severe incident has occurred, and list the EU Member States where the affected product is sold. You are not expected to have a root cause, a fix, or a full technical assessment at this stage. The SRP notifies ENISA and the relevant national CSIRT simultaneously through a single submission.
Step 3: Register the vulnerability report and retain the identifier
The platform assigns a case identifier on submission. Store it against the internal incident record — every subsequent submission (the 72-hour notification, the final report, and any follow-up requests from the CSIRT) is filed as an update to this same case, not as a new CRA vulnerability reporting case.
Step 4: File the 72-hour notification
Submit a fuller technical notification describing the vulnerability or incident in more detail, including corrective or mitigating measures already taken or available. This is where the assessment moves from “we know this is happening” to “here is what we know about it and what we’re doing.” If the CSIRT has raised follow-up questions after the 24-hour warning, address them in this submission.
Step 5: Continue mitigation and monitor for CSIRT contact
Between the 72-hour notification and the final report, the receiving CSIRT may request further information, or may delay onward dissemination of the report on justified cybersecurity grounds — for example where the vulnerability is inside a coordinated disclosure process. If that happens, the CSIRT is required to inform ENISA of the delay and its justification. You do not need to independently chase dissemination status, but you should keep responding to any direct requests.
Step 6: File the final report
For an actively exploited vulnerability, submit the final report within 14 days of a corrective or mitigating measure becoming available. For a severe incident, submit it within one month of the 72-hour notification. The final report should describe the vulnerability or incident, any malicious actors involved where known, how it has been or can be corrected, and what mitigating measures are in place.
There is no statutory deadline for developing the fix itself — the obligation is to report on schedule, not to have solved the underlying problem by a fixed date — but the “without undue delay” standard still applies to remediation.
Step 7: Close and file the record internally
Once the final report is submitted, close the internal incident record against the SRP case identifier and retain the full submission history. This record is what demonstrates compliance if the same vulnerability resurfaces in a different product line, or if a regulator later asks how the organisation typically handles CRA Article 14 events.
Who This Applies To
| Manufacturer scenario | In scope for Article 14 reporting? |
|---|---|
| Product with digital elements currently sold in the EU, launched before 2026 | Yes — legacy products are explicitly not exempted from the reporting duty |
| Product placed on the EU market after 11 September 2026 | Yes |
| Product built on open-source or third-party components | Yes — the reporting duty stays with the manufacturer placing the finished product on the market, regardless of where the vulnerability originates |
| Manufacturer established outside the EU selling into the EU market | Yes — the obligation follows the product into the EU market |
| Product withdrawn from the EU market with no remaining EU users | No — but confirm and document the withdrawal date |
What You Should Have Ready Before an Event Happens
Article 14 does not require a full vulnerability management programme by 11 September 2026 — only the CRA vulnerability reporting obligation itself is live from that date. What it does require is the operational capability to act inside a 24-hour window the moment a trigger occurs. Before that date, confirm you have:
- A registered account on the ENISA Single Reporting Platform, so the 24-hour clock isn’t spent on account setup
- A named internal owner responsible for confirming a trigger and authorising the 24-hour submission
- A documented decision process for distinguishing an actively exploited vulnerability from an unconfirmed report
- Visibility into which EU Member States each product is sold in, since this has to be listed in the first submission
- A CRA vulnerability reporting record-keeping process that ties every submission stage to a single case identifier
Get the CRA Vulnerability Reporting Templates
Building the internal process from scratch under a 24-hour clock is the wrong time to be drafting a decision framework. Our CRA Vulnerability Reporting templates cover the trigger-confirmation checklist, the 24/72-hour submission structure, the final report format, and the internal case-tracking log — ready to adapt to your product line before the clock is running, not during it.
Get the CRA Vulnerability Reporting Templates →
Key CRA Vulnerability Reporting Dates
| Date | Milestone |
|---|---|
| 10 December 2024 | Cyber Resilience Act (Regulation (EU) 2024/2847) entered into force |
| 11 December 2025 | Delegated Regulation (EU) 2026/881 adopted, specifying reporting format and platform details |
| 11 September 2026 | Article 14 reporting obligations apply — the first CRA obligation to take effect |
| 11 December 2027 | Full CRA application — essential cybersecurity requirements, technical documentation, and CE marking |
What is Article 14 of the Cyber Resilience Act?
Article 14 requires manufacturers of products with digital elements to report actively exploited vulnerabilities and severe security incidents to ENISA and the relevant national CSIRT, on a staged timeline of 24 hours, 72 hours, and a final report. It applies from 11 September 2026, well ahead of the rest of the CRA’s obligations, which apply from 11 December 2027.
Does Article 14 reporting apply to products already on the market?
Yes. While most CRA obligations only apply in full to products placed on the market after 11 December 2027, or to legacy products that are substantially modified after that date, Article 14’s reporting duty is carved out from that exemption. It applies to products already on the EU market regardless of when they were placed there.
Where do I submit an Article 14 report?
Through the ENISA Single Reporting Platform (SRP), a centralised system that notifies ENISA and the relevant national CSIRT simultaneously from a single submission.
What has to be in the 24-hour early warning?
Enough to identify the product, confirm that a vulnerability is being actively exploited or a severe incident has occurred, and list the EU Member States where the product is sold. A root cause, a fix, or a full technical assessment is not required at this stage. Our ra-b has the right template for this.
Is there a deadline to actually fix the vulnerability?
No statutory deadline exists for developing a fix. The obligation to act “without undue delay” still applies, and the 14-day final report deadline for vulnerabilities runs from when a corrective or mitigating measure becomes available, not from a fixed date after discovery.
Does the CRA vulnerability reporting duty cover vulnerabilities in third-party or open-source components?
Yes. The duty stays with the manufacturer placing the finished product on the EU market, regardless of where in the supply chain the vulnerability originated.
What counts as a “severe incident” versus an “actively exploited vulnerability”?
An actively exploited vulnerability requires reliable evidence that a malicious actor has exploited it in a live system. A severe incident is a broader trigger covering any event with an actual adverse impact on the security of the product, whether or not a specific vulnerability has been identified as the cause.
What are the penalties for missing an Article 14 deadline?
CRA penalties can reach EUR 15 million or 2.5% of worldwide annual turnover, whichever is higher, under Article 64. Reporting failures are also among the easiest CRA non-compliance issues for a regulator to identify, since the trigger event and the submission timestamp are both independently verifiable.
Do I need a full vulnerability management programme in place by 11 September 2026?
No. Article 14 requires the operational capability to report within the statutory deadlines when a trigger occurs, not a complete vulnerability management system. The practical preparation is registering on the SRP, naming an internal decision-owner, and confirming visibility into where each product is sold — not building out full CRA compliance ahead of its December 2027 deadline.
